Safety shoes are known for their rigid and rugged construction, where comfort is often sacrificed for the benefit of safety. Steel toes for providing rigid protection to a wearer's toes are often required in many safety shoes. The steel toe is incorporated into a shoe by inserting a flange portion of the steel toe under an insole member of the shoe. Some steel toe shoes are made using Opanka construction. Opanka is a type of shoe construction where the shoe upper is hand-sewn, together with a sock liner, to an outsole. Sandals are commonly made using the Opanka construction. To provide flexibility some Opanka construction do not include an insole. However, an example of a footwear construction that employs aspects of Opanka construction with a steel toe and an insole can be found in U.S. Pat. No. 6,067,732, Shoe Construction with Steel Toe, incorporated herein by reference.